ML20046A482
| ML20046A482 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/23/1993 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-93-0205, W3F1-93-205, NUDOCS 9307280171 | |
| Download: ML20046A482 (3) | |
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Entargy Opirttiona,Inc.
F=~ ENTERGY ro w s K;Mna LA 70066
'-e 504 739 6774 R. F. Durski s e.u r Lith y vim;-j 7 W3F1-93-0205 A4.05 PR July 23,1993 U.S. Nuclear Regulatory Commission l
ATTN: Document Control Desk
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l Washington, D.C. 20555
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l
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 d
1 NRC Inspection Report 93-22 Reply to Notice of Violation Gentlemen:
l In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the violation identified in Appendix A of the subject Inspection Report.
If you have any questions concerning this response, please contact Fernando J. Calle at (504) 739-6748.
Very truly yours,
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R.F. Burski Director Nuclear Safety RFB/FJC/stf Attachment cc:
J.L. Milhoan (NRC Region IV), D.L. Wigginton (NRC-NRR),
R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office 9307280171 930723 iT G
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PDR ADOCK 05000382 h a
J W3F1-93-0205-C 4
Attachment to Page 1:of'2 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN 1
APPENDIX A 0F INSPECTION REPORT 93-22 i
i VIOLATION NO. 9322-01 Technical Specification 6.13.1 requires that the licensee have an approved Process Control Program.
Administrative Procedure RW-001-210, " Process Control Program,"
Revision 5, Section 5.4.1.2 requires that annual analysis be performed on the waste streams to determine the isotopic abundance of gamma emitting isotopic in the streams as described in Reference 2.2.8 i
(RW-002-110, " Waste Sample Collection and Isotope Evaluation").
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Technical Procedure RW-002-110, " Waste Sample Collection and Isotope Evaluation," Section 10.18, states, in part, "In order to meet the requirements of 10 CFR 61 for classification of radioactive wastes, Waterford 3 will conduct a program for implementing the waste classification system. This program... includes periodic offsite
[ sample] analysis, at least annually and/or whenever system changes
[ occur] that could impact radionuclide concentration, for all nuclides listed in 10 CFR 61.55 for all waste streams." Section 10.2.3 lists the chemical volume control system filters as an example of a waste stream.
Contrary to the above, the inspector determined on June 11, 1993, that the chemical volume control system filter samples were not collected and submitted for offsite analysis between November 1990 and August 1992.
This is a Severity Level IV violation (Supplement IV) (382/9210-01).
RESPONSE
(1)
Reason for the Violation Entergy Operations, Inc. admits to this violation and believes the root cause was personnel error; specifically, the Radwaste Foreman misinterpreted the sampling requirements intended by procedure -
RW-002-110. He did not interpret Section 10.1.8.1 to require the' sample collection date to be used for defining the annual off-site analysis requirement.
In lieu of the sample collection date, the Radwaste Foreman used the date on which the Radman data base was last updated to ensure compliance with the annual analysis requirement.
' Attachment to W3F1-93-0205 Page 2 of 2
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While the procedure is not explicitly clear as to the date used to comply with Section 10.1.8.1, the procedural intent was to collect and have off-site analysis performed on samoles annually; therefore, the action taken by the Radwaste Foreman was inappropriate.
It should be noted that although a sample was not submitted for offsite analysis between November 1990 and August 1992, a sample was collected and analyzed on-site on November 6, 1991. This analysis confirmed that no Radman data base changes were necessary.
(2)
Corrective Steos That Have Been Taken and the Results Achieved The Radwaste Foreman has been counseled on the correct implementation of RW-002-110 sampling requirements and the importance of self-checking and has been directed to seek a second opinion or'see his supervisor when the procedure appears unclear.
An ongoing QA assessment of 10CFR61 activities identified the chemical volume control system filter sample not being submitted for offsite analysis and also found the same condition for the Boron Management System waste stream sample. The QA assessment identified the CVCS sample prior to the inspection but was not brought up during the exit meeting because the quality specialist involved with the assessment had been out with emergency surgery.
The assessment concludes that there are no generic technical problems with respect to the Waterford 3 waste classification process.
(3)
Corrective Steos Which Will Be Taken to Avoid Further Violations Procedure RW-002-Il0 will be revised to clarify sampling requirements needed to ensurc compliance with 10CFR61.
A lessons learned discussion will be conducted for the staff involved with the sampling and processing of waste streams.
(4)
Date When Full Compliance Will Be Achieved Full compliance will be achieved by September 30, 1993.